Interpreting the State Council's Financial Work Report: Is RWA an Illegal Financial Activity?

China’s State Council classified real-world asset (RWA) tokenization as part of its anti-illegal-financial-activity agenda in a financial work report delivered to the NPC Standing Committee on Nov. 3, placing RWA oversight alongside underground banking and crypto-mining crackdowns rather than innovation or opening-up measures. The report follows the February 2026 joint notice from the PBOC and seven other departments that first grouped RWA tokenization with virtual currency risks under a “strictly banned onshore, strictly regulated offshore” framework, barring “RWA” from business names and scopes, platform marketing and financial institutions’ account, transfer and settlement services. The shift matters because RWA constraints are now embedded in routine supervision rather than special notices, and the report’s separate endorsement of the digital yuan’s repositioning from cash to deposit money signals an official on-chain asset rail is being built even as private tokenized issuance is curbed. Watch for implementing rules and effective dates, and for whether offshore issuance structures using onshore assets and revenues flowing back to mainland users fall under the underground-banking scrutiny line.